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ARTICLE · 05 JANUARY 2021

IRS' Version Of Missing Participant Guidance

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The IRS issued two new pieces of guidance that work together to address missing participants in a qualified plan.

United StatesEmployment and HR
Elizabeth Dold
Elizabeth Dold
David Levine
David Levine
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The IRS issued two new pieces of guidance that work together to address missing participants in a qualified plan. Specifically, the IRS issued Rev. Rul. 2020-24 and Rev. Proc. 2020-46 to add to their existing portfolio on missing participant guidance. This guidance focuses the treatment of escheatment to the state unclaimed property funds with respect to:

  • Reporting and withholding requirements and
  • Indirect rollover relief.

This follows in the line of existing missing participant guidance, which includes required minimum distribution relief under Code Sec. 401(a)(9), reporting and withholding on uncashed checks under Rev. Rul. 2019-19, Internal Revenue Manual guidance, and reporting and withholding of escheatment payments from IRAs under Rev. Rul. 2018-17.

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